Case Title: C. Prakash Vs. Ayngaran International Media Pvt. Ltd.
Date of Order:27th January 2025
Case Number:C.S. (Comm. Div.) No. 132 of 2024
Court:High Court of Judicature at Madras
Presiding Judge:Hon’ble Mr. Justice Abdul Quddhose
Brief Facts of the Case:
The plaintiff, C. Prakash, proprietor of Sri Kumaran CD Collections & Electronics, filed a suit seeking declaratory relief and permanent injunction against Ayngaran International Media Pvt. Ltd. and others. The dispute centered on unauthorized uploads of copyrighted cinematographic works—"Vasuki", "Shenbaga Kottai", and "Dubai Rani"—on the defendants' YouTube channel, "Ayangaran Channel".
The plaintiff claimed ownership of the internet rights to these films, acquired via assignment agreements, and alleged that the defendants' actions amounted to copyright infringement under the Copyright Act, 1957. Despite legal notices, the defendants continued uploading the infringing content, causing revenue loss to the plaintiff.
Key Issues for Determination:
1. Whether the plaintiff had valid copyright ownership of the internet rights for the films in question.
2. Whether the defendants' actions constituted copyright infringement under Sections 51 and 55 of the Copyright Act, 1957.
3. Whether the plaintiff was entitled to damages for the alleged infringement.
Judicial Reasoning and Analysis:
1. Copyright Ownership:
The Court examined the assignment agreements (Exhibits P3 and P6), which granted the plaintiff exclusive internet rights for a 99-year period. The plaintiff also provided evidence of regular uploads on their YouTube channel, "Real Cinemas", demonstrating the exercise of these rights.
Court's Finding: The plaintiff was the lawful copyright owner.
2. Infringement by the Defendants:
The Court found that the defendants had uploaded scenes from the three films on the "Ayangaran Channel" without authorization. The infringing content was verified through screenshots (Exhibit P11) and corroborated by email correspondence (Exhibits P7, P9, P10).
Court's Finding: The defendants committed copyright infringement under Section 51 of the Copyright Act.
3. Damages:
While the plaintiff claimed damages of ₹5,00,000, the Court noted the absence of concrete proof of financial loss. Considering the plaintiff's investment of ₹1,40,000 in acquiring the rights, the Court awarded nominal damages of ₹25,000.Court's Finding: Damages should be limited to ₹25,000.
Decision of the Court:
The Madras High Court granted the following reliefs:
1. Declaration: The plaintiff was declared the sole and absolute copyright owner of the internet rights to the films "Vasuki", "Shenbaga Kottai", and "Dubai Rani" for a period of 99 years.
2. Permanent Injunction: The defendants were restrained from further uploading or exploiting the internet rights to the films in any online format, including YouTube.
3. Mandatory Injunction: The defendants were directed to remove the infringing content from the "Ayangaran Channel" on YouTube.
